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September 27, 2017

ASC Releases Final Rule for AMC Fees; AI Reiterates Concerns

The Appraisal Subcommittee on Sept. 25 published the final rule on the Collection and Transmission of Annual Appraisal Management Company Registry Fees, which establishes the formula for transmitting registry fees to the ASC by states that elect to register and supervise AMCs. The Appraisal Institute reiterated its concern about the final rule.

The final rule is expected to generate millions of dollars in annual AMC registry fees, which are intended to support the development of the new National Registry and to fund grants that will help states with enforcement. The ASC also said it intends to use the fees to support related and undefined Title XI activities.

Fees for AMCs in states that require them to register and be supervised will be assessed as follows:

  • AMCs in business for more than a year will pay $25 for each appraiser who performed an appraisal for the AMC on a covered transaction in the state during the previous year.
  • AMCs in business less than a year will pay $25 for each appraiser who performed an appraisal for the AMC on a covered transaction in the state since the AMC commenced doing business.

The Final Rule was developed and finalized over the objections of the Appraisal Institute and many other industry participants that expressed concern that the AMC Registry Fee rule, as constructed, could hurt small businesses and result in an additional “tax” on small appraisal firms.

The ASC responded to the concerns, stating that it was constrained by the Dodd-Frank Act to assess AMCs based on a $25 per-appraiser formula, and that it had no authority to prohibit an AMC from passing the registry fee to the appraiser. The ASC also stated that the Regulatory Flexibility Act does not require an agency to conduct a small-entity impact analysis if the agency does not regulate the affected entities (AMCs, lenders, appraisers), and that its statutory oversight extends only to state-certifying and licensing authorities.

View the Final Rule


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